Dissecting FATCA: Oil And Gas Trader Edition

Law360, New York (March 8, 2013, 11:40 AM EST) -- On Jan. 28, 2013, the U.S. Department of Treasury issued its final regulations under Sections 1471, et seq. of the Internal Revenue Code of 1986, as amended, otherwise known as the Foreign Account Tax Compliance Act. There is now a clear timetable for foreign financial institutions (FFI), as defined in Code Section 1471(d)(4), to enter into a FATCA agreement with the Internal Revenue Service by the end of 2013, unless they are located in countries with a model 1 intergovernmental agreement (IGA) in place with the U.S. Treasury. FFIs located in countries with a model 2 IGA must still enter into a FATCA agreement with the IRS....

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